Johann T. and Johanna Hess - Page 22

                                       - 22 -                                         
          sec. 5(a), 1959-1 C.B. at 242.  However, respondent argues that             
          the discounted cashflow method should not be used where future              
          income is unpredictable, as with HII, and “the results of such an           
          analysis provide little, perhaps no, indication of value and                
          should be accorded like weight.”  We agree that an income-based             
          method, such as the discounted cashflow method, is not                      
          particularly reliable where the subject company’s future income             
          is relatively unpredictable.  See Wall v. Commissioner, T.C.                
          Memo. 2001-75; Pratt et al., Valuing Small Businesses and                   
          Professional Practices 257 (3d ed. 1998).  Petitioners agree that           
          HII’s sales and earnings are erratic and not readily predictable.           
          Given these circumstances, we are not convinced that the value              
          Mr. Heebink derived under the discounted cashflow method is                 
          entitled to the weight that he gave to it.  However, we believe             
          Mr. Heebink’s conclusions with respect to the discounted cashflow           
          analysis are entitled to some consideration.22                              


               22Mr. Engstrom gave no weight to the discounted cashflow               
          method because small changes in certain assumptions resulted in             
          large changes in the value of HII shares.  Indeed, Mr. Engstrom             
          opined that if HII’s expenses were increased or decreased by 1              
          percent of sales, it would result in a $67,000 per share increase           
          or decrease in the value of HII shares.  He also opined that a 1-           
          percent increase in the discount rate would cause the implied               
          value to go down by $21,000 per share; a 1-percent decrease in              
          the discount rate would cause the implied value to go up by                 
          $26,000 per share; and a combination of a decrease in expenses by           
          1 percent of sales and a 1-percent decrease in the discount rate            
          would result in the implied value to go up by about $100,000 per            
          share.  As we explain later on, we do not agree that this                   
          requires us to completely reject the discounted cashflow method             
                                                             (continued...)           




Page:  Previous  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  Next

Last modified: May 25, 2011